Mark Martin and Thomas Bettge of KPMG in the US discuss the second US Tax Court trial in Medtronic v. Commissioner and consider how the case may ultimately be resolved.
Mark Martin and Thomas Bettge of KPMG in the US describe a July 13 2021 IRS advice memorandum and how its conclusions create risks for taxpayers that true-up unshared stock-based compensation costs under cost sharing arrangements.
Mark Martin and Thomas Bettge of KPMG in the US examine the Inclusive Framework’s July statement on pillars one and two and consider what it has to say about dispute prevention and resolution.
Mark Martin and Thomas Bettge of KPMG describe the US approach to transfer pricing issues involving blocked income, a problem highlighted by recent and upcoming developments.
Mark Martin and Thomas Bettge of KPMG in the US discuss the IRS’ advance pricing agreement (APA) statistics for 2020 and consider the APA programme in the midst of the COVID-19 pandemic.
